American Business Media Thursday filed comments urging the Governors of the U.S. Postal Service to reject the recommended postal rate increase for periodicals made last week by the Postal Regulatory Commission. Although the commission, in its recommended rate schedule, said rates for periodicals would increase an average of 11.7 percent, ABM and others have said rates for publishers unable to co-mail could rise as much as 20 to 35 percent.

ABM, in its filing, said the rate structure, as recommended, "threatens the very core of the periodicals class." The association, whose membership publishes more than 2,000 periodicals, asked the governors to send the recommendation back to the commission for reconsideration. "There is no justification for periodicals rate increases that for many, if not most publications, will be nearly three times the average rate increase for all mail," the association wrote.

The Direct Marketing Association this week also voiced concerns over the recommended rate increase, saying rates for its members could rise as much as 40 percent. DMA has asked the postal governors to reject the PRC’s specific recommendations for flat-shaped mail and to send them back to the PRC for reconsideration. The organization’s comments can be found here.

The problem with the proposed rate structure, said ABM, is not that it encourages co-mailing by giving discounts to those publishers that do so, but that it also punishes those who are unable to co-mail. "The mailing industry is today unable to meet the demand for the co-mailing services that the commission believes will enable publishers to mitigate impact and that some publications, by their very nature, cannot co-mail," wrote ABM. According to the filing, ABM members are already stepping up their efforts to co-mail with the number of publications on pallets growing over the past five years from 57 percent to 74 percent.

ABM cites testimony in postal rate case from Crain Communications, which is unable to obtain co-mailing services for its tabloids and weeklies, and from Hanley Wood, which is able to obtain co-mailing services for only two of its 15 monthlies. "The Commission does not address the plight of the thousands of publications with total circulation below 5,000 for which co-mailing is unavailable," wrote ABM. "For them, there has been no "choice."

Bundle charge
Jamie Boggs, mail list and information systems manager at Shepherdsville, Kentucky-based Publishers Press, said the new bundle charge tied to the rate increase is going to be a logistical challenge for printers. "My understanding is that the post office asked for a container charge and the commission went ahead and said if we need a container charge, we must need a bundle charge too," he said. "We co-mail almost everything. So now, we’re going to have to break everything down and then piece it back together so that we can go back to each publisher with the bundle charge."

Implementation deadline too tight
ABM also said that if the commission does adopt the "punitive" recommended rate increases, it should not implement them on May 6 as the commission has recommended. "If the smallest of publishers feel abused by the rates, just wait until they have to fill out a mailing statement;a form 3541 revised and no doubt enlarged," ABM wrote.

"The Postal Regulatory Commission has deemed it appropriate to recommend adoption of a rate structure so complicated that virtually no publishers have yet, more than a week later, been able to determine with acceptable accuracy what they would pay under the recommended rates," the filing goes on to say. "ABM understands that it will take many weeks before new rules and a new mailing statement are released by the Postal Service."

Boggs said the implementing the recommendations by May 6 will be a programming nightmare. "It’s going to be a really large task to do in a very short time," he said.

Extending the deadline for implementation of the new rates also would give software developers the minimum of two months to develop and implement the new software needed to process them ABM added.